IBCCC releases key resources for Annual Compliance Statement

The committee designed the FAQs to assist code subscribers in identifying, recording, and reporting breaches as part of the ACS program.

Key points from the 2022 ACS webinar

The 2022 ACS webinar reminded insurance brokers that the ACS is the most significant compliance monitoring activity for the IBCCC, and it must include information about reaches and complaints and frameworks for code compliance. It also asks about a subscriber’s overall compliance structure.

The IBCCC encouraged code subscribers to report all breaches and complaints, including “incidents” in the 2022 ACS. Moreover:

Subscribers should use complaints data to track the key issues for clients, including considering whether each complaint breached the code;
Subscribers should review other resources of information to identify code breaches, such as complaints records, file audits, and external audits.

“Breaches can arise in any area of the business, so processes to identify them should include oversight of all areas of the business by trained staff,” it was said during the webinar.

“Provide as much information about a breach as possible,” brokers were told. “The more information, the better! De-identified information about breaches may be used as examples to help the industry learn and improve.”

Insurance brokers not reporting code of practice complaints and breaches

In 2021, multiple insurance brokers claimed they received no complaints and reported no breaches of the code of practice.

The IBCCC deemed the compliance with the code satisfactory. However, it raised concerns about the possible lack of self-reporting.

In a previous statement, the committee emphasised that the new code has more specific provisions to ensure brokers clearly understand their obligations.